South Africa: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Tax Focus: August/September 2025

In South Africa, the Income Tax Act No. 58 of 1962 ("the Act") provides tax exemptions to registered and qualifying Public Benefit Organisations ("PBOs").

South Africa Tax

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SNG Grant Thornton

Women Powering Progress Khanyisa Cingo-Ngandu

"Do whatever you think is best, don't be limited by the path others walked before you."

South Africa Tax

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SNG Grant Thornton

Trade Implications Of ITAC's 15% NEV Battery Tariff Proposal

The International Trade Administration Commission of SA (ITAC ) recently proposed 15% import duties on new energy vehicle (NEV) batteries, many of which currently...

South Africa Tax

Ai

Andersen in South Africa

Africa Tax In Brief

On 29 April 2025, the African Tax Administration Forum ("ATAF") announced that it has commenced a review of its ATAF Income Model Convention (2019), aimed at strengthening the ability of African countries to negotiate tax...

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ENS

ENS Tax In Brief - Issue 146

South Africa Tax

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ENS

How SA Exports May Be Affected By New Tariffs Imposed By USA

South Africa International

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Andersen in South Africa

South Africa's Trade Infrastructure: A Wake-Up Call

South Africa Tax

Ai

Andersen in South Africa

Africa Tax In Brief

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ENS

Viewing The SARB's Exchange Control Revisions Through An IP Licensing Lens

South Africa IP

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Fairbridges Wertheim Becker

ENS Tax In Brief - Issue 137

South Africa Tax

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ENS

ENS Tax In Brief - Issue 136

South Africa Tax

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ENS

Decoding Transfer Pricing: The Commercialisation Of IP For Multinational Corporations

South Africa Tax

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Fairbridges Wertheim Becker

Tax Masterclass: Transfer Pricing (Video)

South Africa Tax

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ENS

VAT Treatment Of Electronic Services: South Africa's Proposed New Regime Released For Public Comment

South Africa Tax

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ENS

Sam Walton's Biggest Mistake: A Lesson In The Fine Print

South Africa IP

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ENS

Intellectual Property Developments In Africa: DJs, Trade Mark Deadlock, And Trade Mark Recordation

South Africa IP

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ENS

From Exclusion To Inclusion: AI, Language And Access To Justice In South Africa

South Africa Technology

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ENS

Parental Leave Rewritten By The Constitutional Court: What Employers Must Do Now

South Africa Employment

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Fairbridges Wertheim Becker

The SCA Confirms Expired Contracts Are Unenforceable When A Suspensive Condition Fails

South Africa Commercial

Ai

Andersen in South Africa

Tax Savvy: Understanding South Africa's Tax Regime For Foreign Enterprises

Expanding your enterprise to a new country is an exciting undertaking, but often comes with its own set of challenges, particularly related to domestic and international tax aspects.

South Africa Tax

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Andersen in South Africa

Navigating Transfer Pricing Challenges In The Mining Sector

The mining sector operates in a dynamic environment characterised by fluctuating commodity prices, complex value chains, and unique operational challenges.

South Africa Tax

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ENS

Tax Disputes: Consideration Of Remedies Other Than Objection And Appeal

South African Revenue Service (SARS) is empowered to raise an original, additional, reduced or jeopardy assessments.

South Africa Tax

SG

SNG Grant Thornton

A Shift In South Africa's Approach On Transfer Pricing Disputes (ABD LIMITED V CSARS, TAX COURT, CASE NO IT 14302)

A recent ruling by the Tax Court in the case of ABD Limited v CSARS marked a notable shift in how South Africa approaches disputes over transfer pricing.

South Africa Tax

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SNG Grant Thornton

Providing Vested Rights In Respect Of Discretionary Trusts

South Africa Commercial

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

Transfer Pricing: Insights On Landmark Judgment

South Africa Tax

Ai

Andersen in South Africa

Africa Tax In Brief

South Africa Tax

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ENS

Customs: Draft Rule Amendments On Transfer Pricing Adjustments

South Africa Tax

Ai

Andersen in South Africa

ENS Tax In Brief

South Africa Tax

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ENS

Transfer Pricing Guide

South Africa Tax

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ENS

South Africa's Long-Awaited Advance Pricing Agreement Programme

South Africa Tax

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ENS

Transfer Pricing: Getting The Basics Right

South Africa Tax

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ENS

ENS Tax In Brief

Below, please find issue 115 of ENS' tax in brief, a snapshot of the latest tax developments in South Africa.

South Africa Tax

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ENS

Transfer Pricing Guide

In line with the trend in most developing countries, transfer pricing has in the last years become a key focus area for the South African Revenue Service ("SARS").

South Africa Tax

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ENS

South Africa's Long-Awaited Advance Pricing Agreement Programme

South Africa has recognised the importance of offering taxpayers greater certainty and predictability in their tax affairs through the recently proposed Advance Pricing Agreement ("APA") programme.

South Africa Tax

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ENS

Transfer Pricing: Getting The Basics Right

Normally, a sales agent and a buy-sell distributor would not be regarded as comparable owing to the differences in functions, assets and risks relevant to each party.

South Africa Tax

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ENS

Africa Tax In Brief

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ENS

Africa Tax In Brief

The African Union's Specialized Technical Committee on Finance, Monetary Affairs, Economic Planning and IntegraAtion recently reiterated its stance that the qualified domestic minimum...

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ENS

Tax Focus - April Edition 2023

On Friday 10 March 2023, the Minister of Finance approved new dispute resolution rules under section 103 of the Tax Administration Act, 2011...

South Africa Tax

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SNG Grant Thornton

Value Chain Analysis – The Future Of Transfer Pricing

As contentious as transfer pricing can be in many respects, there is an established set of principles generally agreed upon under the Transfer Pricing Guidelines for Multinational Enterprises...

South Africa Tax

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ENS

Externalising IP?- What Do You Need To Know

Despite challenges faced in recent years with the global pandemic as well as political and economic instability, South Africa has a booming fintech and technology industry.

South Africa Commercial

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ENS

Tax Updates - Regional Tax Publication, March 2023

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SNG Grant Thornton

What Is Inside The New Rwanda Tax Procedure Law?

South Africa Tax

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ENS

Preparation For A Transfer Pricing Audit: Are You Ready?

South Africa Tax

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ENS

The Untested Waters Of Transfer Pricing Disputes

South Africa Tax

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

SARS Issues Draft Interpretation Note On Intra-group Loans

South Africa Tax

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SNG Grant Thornton

Tax Guide 2022/23

South Africa Tax

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SNG Grant Thornton

Transfer Pricing, Thin Capitalisation And Intra-group Finance Arrangements – SARS Issues Promised Guidance In The Form Of Draft Interpretation Note

South Africa Tax

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ENS

Tax In Brief | Issue 78

South Africa Tax

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ENS

Managing Transfer Pricing Risk During The COVID-19 Pandemic

South Africa Tax

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ENS

Tax In Brief | Issue 69

South Africa Tax

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ENS

Haven't Disclosed Everything To SARS? Tread Carefully

South Africa Tax

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ENS

Africa Tax In Brief - February 2021

South Africa Tax

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ENS

Rwanda Adopts New Transfer Pricing Rules, Embracing OECD Transfer Pricing Guidelines And Anti-BEPS Recommendations

South Africa Tax

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ENS

Africa Tax In Brief

South Africa Tax

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ENS

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Latest Videos

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Tax Masterclass: Transfer Pricing (Video)

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ENS

Webinar | Transfer Pricing Developments In Rwanda: What Does The Future Hold? (Video)

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ENS

Juristconsult NEW Webcast: "IS MAURITIUS READY FOR BEPS?" (Video Content)

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Juristconsult Chambers

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